The OTA and NAS Reports on Biological Control

Ralph W. F. Hardy
Former President
Boyce Thompson Institute
Toronto, Canada
(prepared from the videotaped presentation*)

I'm delighted to see the Ithaca community - Cornell, Boyce Thompson, USDA  pooling their resources to address the topic of biological control. This conference provides an excellent opportunity to deal with biological control in a holistic way. Daryl Lund commented that the Cornell community is in the process of assessing its strengths and deternining its direction. It will be a challenge to put together all the pieces of biological control into what I am going to suggest could be new paradigm a new approach to management of pests. As for what to include in the definition of biological control, my position is an inclusive one: use the current best tools independent of historical definitions to manage pests as auto manufacturers use today's best technology to build cars.

I've been asked to address two reports: the Office of Technology Assessment (OTA) and the National Academy of Sciences' National Research Council (NRC) Board on Agriculture reports on biological control. I am simply a reader of the OTA report as I had nothing to do with its preparation, but I am speaking as chair of the committee that prepared the NRC report.

The OTA report was issued in mid-1995 and the NRC report in late 1995. The OTA is an office of the congress and functions for the congress. Staff write OTA reports and although outside advisory committees have the opportunity to comment, they are not responsible for nor do they control the content of the reports. The OTA report on biological control is a tactical report and is written somewhat consistent with the current administration's commitment to IPM 75 - the goal of 75% of agricultural land being under IPM management by the year 2000.

The NRC report is not associated with government. The members of the National Research Council committee write the report with assistance from the staff. The NRC report is a strategic report. In this report, the NRC introduces a new paradigm, a successor to IPM, a more holistic approach than IPM. This paradigm is ecologically based pest management or EBPM.

The OTA Report

The OTA's role is to advise and provide options, in an unbiased manner, to congress, the ultimate decision-maker. Many options, from impractical to doable, are provided in this report entitled, "Biological Based Options for Pest Control, or BBT. Three congressional committees requested the report: the House Committee on Agriculture, the House Merchant Marine and Fisheries Committee, and the House Committee on Natural Resources subcommittee on National Parks, Forests, and Public Lands. A broad-based advisory panel was appointed to guide OTA, consisting of scientists, industry people, public interest people, a farmer, and a crop consultant. There were also executive liaisons with the administration which is submitting legislation that will impact how USDA, EPA or other government agencies may operate. Many of the 435 references cited consist of non-peer-reviewed information, including letters and conversations.

The charge was to examine the current and potential future role of BBT for pest control. OTA took the traditional approach to biological control, including classical biocontrol, augmentation and conservation, as well as microbial pesticides, pest behavior modification chemicals, and genetic manipulation of pest populations and plant immunizations. Chemical pesticides; physical, cultural, and mechanical controls; plant breeding; and enhanced resistance to pests were not considered. The key points in the report are the following:

Issues and options were identified, the regulatory arena was discussed, and questions were raised about the unevenness of requirements in APHIS--much the same as the comments we've heard today. The need to improve the pipeline from research to implementation was raised: government supported research was reported as being significantly isolated from real needs, and there was a lack of direction for and coordination between research and national priorities.

The OTA report considered commercial aspects of biological control. A panel of private sector people advised that their interest in bio-based technology was low and there would have to be economic changes for their industry to put high priority on bio-based technologies.

The bottom line, in my analysis, of the OTA report is that there needs to be fine-tuning of BBT's for IPM 75 by the year 2000, a very challenging goal. There is no major long-term plan or new-directional thinking in this report although it contains an excellent collection and compilation of data in tables and figures.

The NRC Report

The NRC report was requested and supported by the USDA and the EPA. It was conducted under the Board of Agriculture. I will explain the relationship of the NAS, NRC, and Bureau of Agriculture.

The NRC, an honorific organization, has an operating arm called the National Research Council which provides advice to government. The NRC has a number of boards and commissions, one of which is the Board of Agriculture. The Board of Agriculture initiated this study on biological control in the early 90's. The NAS/NRC is not part of government, but is a private, not-for-profit organization.

The charge for the study and the name of the committee were very carefully worded - the Committee on Pest and Pathogen Control through Management of Biological Control Agents and Enhanced Natural Cycles and Processes. The four special charges given to the committee were:

The committee members felt that we responded to all the charges except the commercial aspect. This was due to insufficient time, and, additionally, the committee did not consider itself competent in this area; we referred readers to the OTA report section on the commercial aspects of biological control.

This committee had 14 members with backgrounds in entomology, plant pathology, nematology, agronomy, economics, industry, extension, and public service. There was a mix of organismal and molecular types. The debate was intense over an extended period of several meetings.

After much debate, we sought consensus with the following question: "What would you like pest management to be in the country 20-25 years from now? As members responded, it became clear that an ecological approach was what everyonewanted to see: a new direction for the new century. The following statement, reflecting that feeling, was entered into the report:

"This committee sees an opportunity to move beyond IPM* and into an information-rich era in which collaborative efforts break down current barriers among the disciplines, institutions, and philosophies, to achieve ecologically based pest management solutions that are safe, profitable, and durable."

Clearly, if you meet these requirements - safety, profitability, and durability - you've produced pest management that should provide comfort to consumers and environmentalists and should answer the needs of the growers.

The committee felt it was extremely important that insect pests, plant diseases, and weed pests be dealt with in a holistic manner and that the various disciplines involved in controlling these pests work together with a common goal. This has not been done up to now.

Ecologically based pest management, or EBPM, is based on the concept that entire farming or forestry systems will rely primarily on inputs of pest biological knowledge and secondarily on physical, chemical and biological supplements for pest management. When necessary, EBPM will be supplemented with an input selected on the basis of its being safe, profitable, and durable.

EBPM will be built on the underlying knowledge of the managed ecosystem, including the natural processes that suppress pest populations. EBPM builds on cultural and biological approaches that were in use prior to widespread application of synthetic chemical pesticides, such as crop rotation, fallowing, intercropping, and organic matter incorporation. There now exists a whole set of tools that can make us much more effective, in the committee's view, in utilizing and understanding that cultural/biological base than we have from the past. EBPM supplements could be biological control organisms or products (pheromones, microbial toxins), or genetically improved plants (insect and disease resistant cultivars). All of these were considered as parts of a whole with no compartmentalization. EBPM does not compartmentalize biological control into those tactics that may be included and those that are excluded.

EBPM includes chemical, physical and biological strategies which meet the objectives of safety, profitability, and durability. Safety is defined as safe to growers, workers, processors of the materials used, and consumers of the food produced. Profitability means cost effective as well as effective, easy to implement and readily integrated into crop production practices. Durability means long-term management of pests without adverse environmental, economic, or safety consequences such as development of pest resistance.

Two chapters of the report are especially pertinent to this conference: The chapter on research recognizes that managed ecosystems are very complex situations. Coordinated, multidisciplinary, and inter-disciplinary research will be necessary to develop and implement EBPM. This means the focused work of a research, product development, and commercialization team not unlike what is routinely done in industry.

Eight priority research areas were identified. They are:

  1. The ecology of managed ecosystems
  2. Behavioral, physiological, and molecular mechanisms to affect EBPM
  3. Identifying and conserving natural resources necessary for EBPM
  4. Developing improved research and diagnostic techniques
  5. Ecologically based crop protection systems
  6. Implementation and evaluation of EBPM
  7. Improving understanding of societal and economic forces, especially those affecting of EBPM
  8. Developing new institutional approaches to encourage the necessary cooperation

The NRC Report was received enthusiastically by senior USDA and EPA management.

The public oversight chapter contains detailed recommendations for principles that APHIS, USDA, and EPA might use in the regulatory process. Some of these principles are:

Draw on the experience and experimentation base that exists. By definition, synthetic pesticides are a novel material, so there is no experience base, from a health and environmental point of view, with these chemicals. That is why one has to go through the extensive environmental and health testing. In contrast, there is an experience base for biological organisms and products because of their existence in nature. This is valid for organisms or for genes and gene products. This experience base may guide risk evaluation. The report suggests that the regulatory process should begin at the existing experience base.

Risk evaluations should set priorities and not be a "what if" list. Risk evaluation should be advjusted to recognize scale of use. The risk is greater for a supplement used on 70 million acres than 70 thousand acres.

The oversight agencies need to put together a road map that will guide industry or n ot-for-profit institutions through the steps necessary for registration. In general, the agencies should make the regulatory process more user-friencdly. "One-stop shopping" would be ideal for regulatory oversight but is not a realistic possibility in the foreseeable future. Conditional registration, as suggested by Becky Goldburg, might be an interesting way to accelerate initial approval with follow-up monitoring.

Persistence is another issue that must be dealt with when regulating these organisms. We reiterated that risk is product-based, not process-based. We did not distinguish between transgenic products or products coming from what might be called a natural process of plant breeding.

Monitoring was addressed. Clearly there needs to be monitoring. We didn't think it appropriate for bureaucracies to get involved in monitoring, but there needs to be monitoring by the grower and by the input provider following introductions. We are currently seeing examples of that in transgenic crops with the Bt gene.

What are the next steps? Mainly the concept of communication. The Under Secretary of Research, Education, and Economics, the USDA-APHIS, and the EPA are all strongly enthusiastic about EBPM. The NRC Board of Agriculture will meet later this month with key USDA, and EPA leadership to further discuss EBPM and how we might proceed. The NRC report proposes broader communication with Washington science leadership and also communication with relevant professional societies so that this message can be more widely communicated

In closing, I will read the last paragraph of an op/ed that the committee released last week:

"Converting to EBPM will take substantial time. The necessary knowledge needs to be developed, the new procedures need to be implemented. By shifting the emphasis from control to management, we can strengthen the ecosystem on which we all depend. As populations continue to grow, as we begin the transition from petroleum based to biological-based industrial and consumer products, this new paradign will become essential."


Questions

Ray Carruthers, USDA/ARS: Did the committee see any way in which farmers can be involved in pest management in the future? Were the recommendations meant to change the relationship of farmers in pest management, or are they urging researchers to do a better job of providing a better package to farmers, or was the committee talking about a different way in which farmers and researchers should be involved in pest management.

Answer: There was debate in terms of who was going to deliver EBPM to the farmer. The majority felt that the contract consultant to the grower will probably become the main deliverer. The extension system needs to figure out how it is going to deliver information to those contract consultants. In the US, individual farmers are increasingly contracting with a consultant to provide a whole host of input: what varieties should be planted, pest management recommendations, etc. The number of contract consultants in this area is expanding rapidly, and consultantsare a very good way to deliver pest management information. They will educate each farmer and make the critical decisions.

An institution like Cornell needs to determine how their Extension people will interphase in the process of information delivery as guidance to farmers decreases and contract consulting grows.


*The committee views IPM in its current form as a primarily insect-pest approach with little emphasis on other pests.


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